Lofton v. Bolin Grove Farms, LLC
Circuit Court of DeSoto County, Mississippi · Cir. Ct. DeSoto Cty., Miss. · Mississippi bar guidance
Verified September 29, 2026
- Citation
- Lofton v. Bolin Grove Farms, LLC, Cause No. CI2021-00059CWD, Order on Defendant Briggs Equipment, Inc.'s Motion to Dismiss (Miss. Cir. Ct. DeSoto Cty. Sept. 26, 2025) (Wilson, J.), MEC Doc. 200
- Decided
- September 26, 2025
Summary
Briggs Equipment, Inc., a defendant and cross-defendant, moved to dismiss for discovery abuse and sought fees. In responding, plaintiffs' counsel Vanessa Price 'relied almost exclusively on either fictitious cases or cases that do not stand for the legal principle or quotation for which they were cited.' Briggs flagged the citations in its July 1, 2025 reply, and on September 2, 2025 the court ordered counsel to produce the cases or explain. Her response acknowledged that all 'fourteen (14) such citations' were nonexistent or unsupportive and attributed them to 'an artificial intelligence research tool.' A separate order had already awarded Briggs fees 'as a sanction for Attorney Price's reliance on hallucinated cases' in her response to Briggs' summary-judgment motion. Judge Celeste E. Wilson found that counsel's 'reliance upon artificial intelligence to respond to Briggs' motion was a deliberate act, as was her decision to blindly rely upon the authorities produced thereby.'
- AI tool:
- An AI research tool the attorney associated with Fastcase (the order records her citing "FastCase, a paid service rendered by the Mississippi Bar," as a source of the citations; she also cited general internet research)
- Sanction amount:
- $7,472 in attorneys' fees and costs to Briggs Equipment, Inc., payable by counsel personally (a separate $37,584.91 fee award in the same order was for discovery abuse)
What sanction did the court impose?
For 'no fewer than fourteen' erroneous citations, the court imposed sanctions against counsel: $7,472.00 in Briggs' fees and costs for responding to both filings, payable by her within 30 days; six hours of approved CLE on artificial intelligence; sending a certified copy of the order to The Mississippi Bar 'for review' (she had told the court she self-reported); and a letter to her clients explaining her reliance on AI. In the same order the court dismissed plaintiffs' claims against Briggs with prejudice for discovery abuse and, under the Litigation Accountability Act, assessed a separate $37,584.91 fee award against counsel alone, finding that she 'not only condoned such misconduct but actively engaged in it.'
Why does Lofton v. Bolin Grove Farms, LLC matter for law firms using AI?
Lofton shows a trial court sanctioning an attorney for AI-generated citations in the same order that dismissed her clients’ claims for discovery abuse. Counsel attributed the fourteen erroneous citations to an AI tool she associated with Fastcase, which the order describes as “a paid service rendered by the Mississippi Bar.” The court found that the Bar’s making such a tool available was not “any sort of justification” for “wholesale reliance on what such AI tool generated without the exercise of any sort of quality control.” It called her claim to have Shepardized each case “particularly dubious” and explained that finding “no negative history” is not enough, and counsel “cannot perform such duties where she does not read and ensure the accuracy of the cases cited in her own court filing.”
The order also rejected the claim that the errors were “inadvertent”: “Counsel’s reliance upon artificial intelligence to respond to Briggs’ motion was a deliberate act.” Firms documenting their AI-use practices may wish to note that the sanctions here included a letter to the clients explaining counsel’s reliance on AI, in addition to fees, CLE and notice to the Bar.
Sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.
- The cited copy is a third-party tracker's mirror of the order (MEC Document 200, filed 09/26/2025). No court-hosted copy is reachable: Mississippi Electronic Courts public access requires registration and paid use.